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Filing # 118603732 E-Filed 12/22/2020 10:56:16 AM
IN THE CIRCUIT COURT OF THE 14"
JUDICIAL CIRCUIT IN AND FOR
BAY COUNTY, FLORIDA
CASE NO.: 19004412CA
JAMIE AND JENNIFER CARR,
Plaintiffs,
Vv.
GULFSTREAM PROPERTY & CASUALTY
INSURANCE COMPANY
Defendant.
PLAINTIFFS’ FACT AND EXPERT WITNESS LIST
COME NOW Plaintiffs, JAMIE AND JENNIFER CARR, by and through their
undersigned attorneys, file their Fact and Expert Witness List pursuant to the Trial Order, and state
as follows:
FACT AND EXPERT WITNESS LIST
1. All parties to this action and their representatives.
2. Jose Puentes
Expert Inspections, LLC d.b.a. iTestenvironmental
14411 Commerce Way, #300-C
Miami Lakes, Florida
Mr. Puentes is expected to testify as to any and all mold issues that have arisen in
relation to the claim at issue. While testifying, he will rely upon his site inspection/s,
education, training and experience, and all additional relevant physical evidence of
record, including discovery materials and facts presently existing and which may
develop as discovery continues. He is also expected to testify regarding the respective
costs of the work performed and/or to be performed.
3. Jack Husband, P.E.
Southeastern Consulting Engineers, Inc.
P.O. Box 141
Wewahitchka, FL 32465Mr. Husband is expected to testify as to any and all issues that have arisen in relation
to the claim at issue. While testifying, he will rely upon his soon to be scheduled on-
site inspection, education, training and experience, and all additional relevant physical
evidence of record, including discovery materials and facts presently existing and
which may develop as discovery continues.
4. Marshall Austin
Total Claim Source, LLC
PO Box 1054
Crystal Springs, FL 33524
Mr. Austin is expected to testify as to any and all issues that have arisen in relation to
the claim at issue. While testifying, he will rely upon his soon to be scheduled on-site
inspection, education, training and experience, and all additional relevant physical
evidence of record, including discovery materials and facts presently existing and
which may develop as discovery continues. He is also expected to testify regarding the
respective costs of the work to be performed.
5. Any and all witnesses listed in Defendant’s Witness List.
6. Rebuttal and impeachment witnesses as needed.
7. Expert witnesses listed on Defendant’s Expert Witness List.
8. All persons who are identified in any pleadings in this case.
9. All persons or entities named in any depositions and exhibits thereto, answer to
interrogatories, insurance claim reports, or other discovery taken in this case.
10. All persons named in response to request for production of documents by the parties in
this case.
11. All persons who have conducted investigations of the Plaintiffs’ Property.
12. All persons named in any documents produced in response to notices of production
from non-parties propounded in this case.
Plaintiffs reserve their right to amend or supplement this witness list as discovery is
currently ongoing.CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served on
this 22nd day of December, 2020, via the Florida E-Filing Portal to: Kathy J. Maus, Esq., Butler
Weihmuller Katz Craig LLP, 400 North Ashley Drive, Suite 2300, Tampa, FL 33602,
kmaus@butler. legal.
BY:
GED LAWYERS, LLP
Attorneys for the Plaintiffs
7171 North Federal Highway
Boca Raton, FL 33487
Telephone: (561) 995-1966
Facsimile: (561) 241-0812
Primary Email: pdlitlaw@gedlawyers.com
Secondary Email:bgoetsch@gedlawyers.com
/s/ Scott M. Rosso
SCOTT M. ROSSO, ESQ.
Florida Bar No.: 505757
DAVID R. SHAHEEN, ESQ.
Florida Bar No.: 0117947